Nuclear medicine and the proposed national radioactive waste dump

To download a 2-page paper addressing these issues right-click here.

Nuclear waste and nuclear medicine in Australia

Jim Green, Online Opinion, 16 Nov 2021

https://www.onlineopinion.com.au/view.asp?article=21721&page=0

Claims that the Australian government’s proposed national nuclear waste storage and disposal ‘facility‘ near Kimba in South Australia is required to support nuclear medicine are not supported by the facts.

Australia’s radioactive waste arises from the production and use of radioactive materials in scientific research and industrial, agricultural and medical applications. The Australian Nuclear Science and Technology Organisation (ANSTO), operator of the research reactor at Lucas Heights, south of Sydney, is the main source of waste destined for a national nuclear waste facility. (Other waste streams ‒ such as those generated at uranium mines, and wastes from nuclear weapons testing ‒ would not be disposed of at the national facility.)

The vast majority of nuclear medicine procedures are diagnostic imaging procedures; the remainder are for therapy or palliation (pain relief). According to Medicare figures, nuclear medicine represents less than three percent of medical imaging. Nuclear medicine should not be confused with X-rays using iodine contrast, radiotherapy or chemotherapy, which are used much more commonly.

ANSTO is increasing production of nuclear waste from its radioisotope export business ‒ it plans to ramp up production of technetium-99m, the most commonly used medical radioisotope, from one percent of global supply to 25-30 percent. When all costs, including final waste disposal, are considered, this business costs taxpayers and leaves Australia with much more radioactive waste. The government subsidy to ANSTO for 2019-20 alone was $282 million.

The federal government claims that waste storage at Lucas Heights is reaching capacity and that failure to find a new waste storage or disposal site will impact on medical radioisotope supply and thus adversely affect public health.

Those claims ignore several important points:

* Nuclear medicine typically uses short-lived radioisotopes and the waste does not require special handling after a short period of radioactive decay.

* The absence of a national waste storage or disposal facility has not adversely impacted nuclear medicine, nor will the establishment of such a facility improve nuclear medicine.

* Waste can be safely stored at Lucas Heights for decades to come, as has been acknowledged by the national nuclear regulator, by the Australian Nuclear Association, and even by ANSTO itself.

Before delving into those arguments, it should be noted that only a small fraction of the waste generated at Lucas Heights ‒ and an even smaller fraction of radioactive waste generated nationally ‒ arises from the production or use of medical radioisotopes. Keith Pitt, the minister responsible for radioactive waste management, claims that “more than 80 per cent of Australia’s radioactive waste stream is associated with the production of nuclear medicine”. A figure of just 20 percent would be closer to the mark; less than 1 percent if uranium mine wastes are included in the calculations.

In any case, the fact that some waste is of medical origin doesn’t mean that a poorly designed and executed plan for a national waste facility should be accepted. The current plan for a waste facility near Kimba is contentious and problematic for numerous reasons, not least the unanimous opposition of the Barngarla Traditional Owners and the government’s extraordinary refusal to allow Traditional Owners to participate in a ‘community ballot’. The racism has been so crude that it attracted criticism from Coalition MPs (and others) on federal parliament’s Joint Committee on Human Rights.

Another concern is that the National Health and Medical Research Council’s ‘Code of practice for the near-surface disposal of radioactive waste in Australia’ states that a repository should not be built on agricultural land. Thus the Kimba site should have been precluded from consideration.

Scare-mongering

Regardless of the outcome of the current push for a national waste facility ‒ and bearing in mind that all previous plans have been abandoned ‒ there will be an ongoing need for hospitals to store clinical waste. After nuclear medicine is used in a patient, the vast majority is stored on site while it decays. Within a few days, it has lost so much radioactivity that it can go to a normal rubbish tip. There will always be multiple waste storage locations even if a national facility is established.

The government’s claim that a national waste facility is urgently required lest nuclear medicine be affected amounts to scare-mongering. Tilman Ruff, Associate Professor at the Nossal Institute for Global Health at Melbourne University, notes: “The emotive but fallacious claim that provision of nuclear medicine services needed for diagnosis and treatment of cancer will be jeopardised if a new nuclear waste dump is not urgently progressed is being dishonestly but persistently promoted.”

Likewise, health professionals noted in a joint statement in 2011: “The production of radioactive isotopes for nuclear medicine comprises a small percentage of the output of research reactors. The majority of the waste that is produced in these facilities occurs regardless of the nuclear medicine isotope production. Linking the need for a centralised radioactive waste storage facility with the production of isotopes for nuclear medicine is misleading.”

Nigel Scullion, then a Coalition Senator, said in 2005 that “Australia will not get access to radiopharmaceuticals” if a nuclear waste repository site was not quickly cleared of any impediments.

Indeed Scullion claimed that access to medical radioisotopes would cease by the end of 2006. Fifteen years later, access to radioisotopes has not been affected and the sky hasn’t fallen in ‒ but Coalition MPs continue with their cynical scare-mongering.

Go back another decade, and the Howard government was scare-mongering to win support for its plan to replace the HIFAR research reactor at Lucas Heights with a new reactor. It wasn’t at all clear that a domestic reactor was required for medical radioisotope production. After all, countries such as the US, the UK and Japan had sophisticated nuclear medicine with little or no reliance on domestic reactor supply.

Indeed there were expert views that a new reactor would adversely affect public health. Prof. Barry Allen, a former chief research scientist at ANSTO, Head of Biomedical Physics Research at the St. George Cancer Care Centre, and author of over 220 publications, told Radio National’s Background Briefing program in 1998:

“I mean it’s reported that if we don’t have a reactor, people will die because they won’t be getting their nuclear medicine and radioisotopes. I think that’s rather unlikely. Most of the isotopes can be imported into Australia; some are being generated on the cyclotron. But on the other hand, a lot of people are dying of cancer and we’re trying to develop new cancer therapies which use radioisotopes, which emit alpha particles which you cannot get from reactors. And if it comes down to cost benefit, I think a lot more people would be saved if we could proceed with targeted alpha cancer therapy, than being stuck with a reactor when we could in fact have imported those isotopes.”

ANSTO’s Lucas Heights site

ANSTO’s Lucas Heights site cannot be used for disposal of nuclear waste. It is unlikely that the site would meet relevant criteria, and in any case federal legislation prohibits waste disposal there.

But nuclear waste can be (and is) stored at Lucas Heights; indeed much of the waste destined for a national facility is currently stored there.

Claims that storage capacity at Lucas Heights is nearing capacity and that a national waste facility site is urgently needed have been flatly rejected by Dr Carl-Magnus Larsson, CEO of the federal nuclear regulator, the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA). Dr Larsson stated in parliamentary testimony in 2020: “Waste can be safely stored at Lucas Heights for decades to come”.

Similar comments have been made by ANSTO officers, by the federal government department responsible for radioactive waste management, and by the Australian Nuclear Association. ANSTO officers have noted that “ANSTO is capable of handling and storing wastes for long periods of time” and that waste is stored there “safely and securely”.

Long-lived intermediate-level waste

Of particular concern is long-lived intermediate-level waste (ILW) including waste arising from the reprocessing of irradiated nuclear fuel from the OPAL research reactor at Lucas Heights as well as earlier research reactors. The government plans to move this ILW to the Kimba site for above-ground storage while a deep underground disposal site is found. (Lower-level wastes will be permanently disposed of at Kimba if the project proceeds.)

But the process of finding an ILW disposal site has barely begun and will take decades; indeed ARPANSA has flagged a timeline of 100 years or more.

The vast majority of ILW is currently stored at Lucas Heights. Why not leave it at Lucas Heights ‒ described by an ANSTO officer as “the most secure facility we have got in Australia” ‒ until a disposal site is found? The government doesn’t have a good answer to that question ‒ indeed it has no answer at all beyond false claims about storage capacity limitations and scare-mongering about nuclear medicine supply.

Until such time as a disposal site is available, ILW should be stored at Lucas Heights for the following reasons:

* Australia’s nuclear expertise is heavily concentrated at Lucas Heights;

* Storage at Lucas Heights would negate risks associated with transportation over thousands of kilometres;

* Security at Lucas Heights is far more rigorous than is proposed for Kimba (a couple of security guards); and

* Ongoing storage at Lucas Heights avoids unnecessary costs and risks associated with double-handling, i.e. ILW being moved to Kimba only to be moved again to a disposal site.

Conversely, above-ground storage of ILW in regional South Australia increases risk, complexity and cost ‒ for no good reason.

Need for an independent inquiry

The current plan for a waste facility at Kimba should be scrapped. It is unacceptable to be disposing of nuclear waste against the unanimous wishes of Barngarla Traditional Owners, and ILW storage at Kimba makes no sense for the reasons discussed above.

Australia needs a thorough independent inquiry of both nuclear waste disposal and production. We need a long-term disposal plan that avoids double-handling and unnecessary movement of radioactive materials and meets world’s best practice standards.

An inquiry should include an audit of existing waste stockpiles and storage. This could be led by the federal nuclear regulator ARPANSA in consultation with relevant state agencies. This audit would include developing a prioritised program to improve continuing waste storage and handling facilities, and identifying non-recurrent or legacy waste sites and exploring options to retire and decommission these.

An inquiry would also identify and evaluate the full suite of radioactive waste management options. That would include the option of maintaining existing arrangements until suitable disposal options exist for both ILW and lower-level wastes.

Radioisotope production options

We also need to thoroughly investigate medical radioisotope production options with the aim of shifting from heavy reliance on reactor production in favour of cyclotrons (a type of particle accelerator). Among other advantages, cyclotrons produce far less radioactive waste than research reactors.

PET scanning is the fastest growth segment in nuclear medicine. Overwhelmingly this is used in cancer diagnosis and increasingly in therapy, and relies only on cyclotrons for supply.

We have a choice: whether we follow ANSTO’s expensive business model to ramp up reactor manufacture of radioisotopes ‒ and the long-lived radioactive waste that goes with it ‒ or collaborate with Canada and other countries to develop cyclotron manufacture of radioisotopes that does not produce long-lived nuclear waste.

ANSTO is a taxpayer-funded organisation. The decision to ramp up reactor waste production will leave many future generations with radioactive materials that last hundreds of thousands of years.

Clean cyclotron production of technetium-99m was approved in Canada last year, and should become the future of radioisotope production. It avoids the accident and terrorist risks of nuclear reactors, has no weapons proliferation potential, and creates very little nuclear waste.
Cyclotron radioisotope manufacture at multiple sites will also be more reliable than our single reactor, which has a record of multiple unplanned outages.
We should be leaders in this field, not laggards.

Dr Jim Green is the national nuclear campaigner with Friends of the Earth Australia. His PhD thesis on the replacement of the Lucas Heights nuclear reactor focused on medical radioisotope supply options for Australia.

More information:

* Dr Margaret Beavis and Dr Peter Karamoskos (Medical Association for Prevention of War), 2017, ‘Ten more questions about Australia’s nuclear waste’

* Medical Association for Prevention of War, 2017, Submission to ARPANSA re medical radioisotope production

* Medical Association for Prevention of War − nuclear medicine

* Video: ‘Debunking the myths around medicine and a nuclear waste dump‘

* Friends of the Earth: nuclear waste / medicine

* Friends of the Earth: ANSTO, radioisotope production, etc.

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Nuclear medicine and the proposed national radioactive waste dump

Jim Green, December 2015

National nuclear campaigner – Friends of the Earth, Australia

To download a 2-page paper addressing these issues right-click here.

“As health organisations, we are appalled that access to nuclear medical procedures is being used to justify the proposed nuclear waste dump. Most waste from these procedures break down quickly and can be safely disposed of either on site or locally.”  − Dr Bill Williams, Medical Association for the Prevention of War

“Linking the need for a centralized radioactive waste storage facility with the production of isotopes for nuclear medicine is misleading. The production of radioactive isotopes for nuclear medicine comprises a small percentage of the output of research reactors. The majority of the waste that is produced in these facilities occurs regardless of the nuclear medicine isotope production.” − Nuclear Radiologist Dr Peter Karamoskos

Summary

Proponents of a national radioactive waste facility (a repository for lower-level wastes and a co-located store for higher-level wastes) claim or imply that nuclear medicine would be jeopardised if the facility does not proceed. There is no basis to such claims – they amount to dishonest scare-mongering.

Proponents claim that most or all of the waste that the federal government wants to dispose of or store at a national repository/store arises from medicine, specifically the production and use of medical radioisotopes. However, measured by radioactivity, the true figure is just 10-20%. Measured by volume, the figure may be within that range or it may be higher than 20% − but it takes some creative accounting to justify the claim that most or even all of the waste is medical in origin.

In any case, the fact that some waste is of medical origin doesn’t mean that a national repository/store is the best way to manage the waste.

If the plan for a national repository/store does not proceed, medical waste will continue to be stored at the Lucas Heights reactor site operated by the Australian Nuclear Science and Technology Organisation (ANSTO) and, in much smaller volumes, at hospitals. Some waste is used in hospitals and then sent back to ANSTO (e.g. molybdenum ‘cows’ that have been ‘milked’ of the daughter radionuclide, technetium-99m − by far the most commonly used medical radioisotope). That is no problem since ANSTO and hospitals continue to produce radioactive waste and thus they have an ongoing need for on-site waste stores and waste management expertise regardless of the options for periodic off-site disposal.

Nuclear medicine is not being adversely affected by the absence of a national radioactive waste repository/store. Nuclear medicine will not benefit from the creation of a national radioactive waste repository/store.

The incessant references to nuclear medicine to ‘sell’ the proposed radioactive waste repository/store amount to nothing more than emotive propaganda − which is what critics of the proposed national radioactive waste repository/store are routinely accused of.

Scare mongering

Successive governments have engaged in a scare campaign in relation to medical isotopes. Here are some examples:

·         Senator Nigel Scullion, who purports to represent the NT in the Federal Senate, said: “If we don’t have a site that is clear of any impediments by April [2006] then by December 2006 Australia will not get access to radio pharmaceuticals that are essential to the early diagnosis of cancer and to deal with many cardiovascular issues in Australia.” (13/10/05, abc.net.au/news/newsitems/200510/s1481671.htm) Senator Scullion’s scare-mongering was proven to be false.

·         A joint media released by Nigel Scullion and David Tollner, the CLP Member for Solomon in the NT Parliament, said: “A delay [in building the waste facility] would severely limit the availability of life-saving radiopharmaceuticals used in the treatment of cardiovascular disease and early intervention against cancer, particularly breast cancer.” That one paragraph contains layers of confusion and misinformation. As the Medical Association for the Prevention of War noted, Senator Scullion and Mr Tollner were “peddling a lie” (ABC, 17/10/05).

·         National MP John Cobb said: “But let me ask this: do people want hospitals, do they want life-saving cancer treatment and equipment …? … I must stress how much medical waste is involved. I wonder whether those who have such a problem with it want to close down our hospitals.” (House of Representatives, 16 October 2003, pp.21329-30) Needless to say, no hospitals have been closed down, no hospitals will be closed down, no-one wants hospitals closed down.

·         In 2002, science minister Peter McGauran accused WA Premier Geoff Gallop of putting at risk life-saving nuclear medical research by refusing to accept that its waste had to be stored somewhere. (‘Premiers dump on waste site’, The Australian, August 7, 2002.)

Much of the pro-dump propaganda is somewhat less disingenuous than the comments of Senator Scullion, Mr Tollner, Mr Cobb, and Mr McGauran, implying rather than asserting that nuclear medicine would be jeopardised if the NT dump plan does not proceed. For example federal resources minister Martin Ferguson said in 2010: “We need a repository. We need nuclear medicine. All Australians benefit from the outcome of establishing a low and medium level repository in Australia, because half a million Australians a year demand access to nuclear medicine.” (www.abc.net.au/local/stories/2010/03/04/2836622.htm)

David Tollner said he approached then Prime Minister John Howard about funding an oncology unit at Royal Darwin Hospital as compensation for hosting a nuclear waste facility. (16/10/05, abc.net.au/news/newsitems/200510/s1483293.htm) If there is a need for an oncology unit in Darwin, it would be totally unacceptable for federal support to be dependent on acceptance of a nuclear waste dump.

Fraction of the radioactive waste of medical origin

The federal Labor government − as with the previous government − routinely asserts that most of the waste is a by-product of the production and use of medical isotopes. Sadly, that false claim is sometimes echoed in the NT, as with the August 2011 NT News editorial which asserted that the waste arises “almost solely” from nuclear medicine.

Here are some examples of politicians peddling misinformation:

·         Then resources minister Ian Macfarlane said the nuclear waste arises “predominantly from medical services” (6/6/05, www.abc.net.au/lateline/content/2005/s1385915.htm).

·         Then science minister Peter McGauran said: “However, the Government remains totally and utterly committed to the safe and secure storage of low level radioactive waste − the bulk of which is produced from nuclear medicine procedures, and is the necessary by-product of life-saving medicine.” (24/6/2004, www.abc.net.au/worldtoday/content/2004/s1139557.htm)

·         Mr McGauran said that the waste destined for the national dump “is largely produced by nuclear medicine” (ABC Radio National, Australia Talks Back, 5/2/02).

·         In 1997, Mr McGauran said that “During this year more than 260 000 Australians will have a nuclear medicine procedure. … As a result of these procedures, some 35 spent fuel rods are generated by the Lucas Heights research reactor every year.” However just 10% of the spent fuel can be attributed to medical radioisotope production.

·         Then science minister Brendan Nelson said on 2/11/05 in Parliament that “… much of [the nuclear waste is] sourced from hospitals around Australia, which is currently stored at ANSTO. We have another 1,800 cubic metres at Woomera, much of that sourced from hospitals. In fact most of this stuff comes from hospitals. …” Hospitals account for only a tiny fraction of the waste (about 3% by volume). Just over 2000 cubic metres of low-level waste are stored at Woomera and none of it is of medical origin. Mr Nelson had no idea what he was talking about.

For low-level waste (LLW) and short-lived intermediate-level waste (SLILW):

* The claim that most of the waste is of medical origin certainly cannot be true in relation to waste volume, since 54% of the volume is non-medical CSIRO soil.

* A rough estimate would be as follows: say one quarter of ANSTO’s waste is medical (1320/4=330m3), and one third of the state/territory waste is medical (151/3=50 m3), so overall perhaps ONE TENTH (380/3700 m3) of the national inventory of LLW/SLILW is a by-product of medical isotope production and nuclear medicine. Or if we assume that one half of ANSTO’s waste is medical (1320/2=660m3), the overall figure is 710/3700 or 19%.

For long-lived intermediate-level waste (LLILW):

* Only a small fraction of this waste could be attributed to medical isotope production. Spent fuel accounts for a large majority of the radioactivity of Australia’s LLILW (though only a small fraction of the volume), and according to ANSTO (1993 Research Reactor Review submission), just 10% of the Lucas Heights ‘HIFAR’ reactor’s neutrons were used for medical isotope production. Presumably a similar figure applies for the new OPAL reactor − there is no reason to believe otherwise.

* Of the rest of Australia’s LLILW (other than spent fuel), about half by volume comprises reactor and isotope production wastes (limited detail is available), but this would account for only a small fraction of the LLILW inventory when measuring by radioactivity.

In sum, for LLW plus SLILW plus LLILW, 10-20% of the current stockpile would be the plausible range for medical waste − closer to 10% if measuring by radioactivity (because spent reactor fuel is such a large contributor to total radioactivity) and closer to 20% if measuring by volume.

For current and future production, roughly 30-40% of the volume could be attributed to medicine, but if measuring by radioactivity the figure would still be in the range of 10-20% (again because the radioactivity figures are dominated by spent fuel).

What should be done?

Two parallel processes should be initiated regarding radioactive waste management in Australia: a radioactive waste audit, and a National Commission or comparable public inquiry mechanism.

The federal government should immediately initiate an audit of existing waste stockpiles and storage. This could be led by the federal nuclear regulator ARPANSA in consultation with relevant state agencies with responsibility for radioactive waste. This audit would include developing a prioritised program to improve continuing waste storage and handling facilities, and identifying non-recurrent or legacy waste sites and exploring options to retire and de-commission these.

A National Commission would restore procedural and scientific rigour, and stakeholder and community confidence in radioactive waste management. It would identify and evaluate the full suite of radioactive waste management options. That would include the option of maintaining existing arrangements, keeping in mind that 95% of the waste is securely stored at two Commonwealth facilities: ANSTO’s Lucas Heights facility, and a large volume of very low level waste stored on Defence Department land at Woomera, SA.

The above issues are addressed in detail in a 2014 paper posted at: https://nuclear.foe.org.au/wp-content/uploads/Responsible-Radioactive-Waste-Management-The-need-for-an-Inquiry-Final.pdf

More information

−−− ‘Nuclear Medicine in Australia: a Joint Health Sector Position Statement’, March 2011, www.mapw.org.au/files/downloads/JHPS_Nuclear-Medicine-%20in%20Australia%20March%202011.pdf

(“Nuclear medicine involves the use of radioisotopes for the diagnosis and treatment of medical conditions. Significant concerns exist within the Australian community and amongst health professionals and scientific experts regarding current research reactor based production and the Commonwealth Government’s position regarding the disposal of these radioisotopes. On the basis of current information, we, the undersigned members of the health sector, recommend that the nuclear medicine industry in Australia undergo a full independent inquiry.”)

−−− Medical Association for Prevention of War − nuclear medicine section:
www.mapw.org.au/nuclear-chain/nuclear-medicine

−−− Friends of the Earth webpages on nuclear medicine, radioisotope production, and Lucas Heights: www.nuclear.foe.org.au/ansto

−−− Dr Margaret Beavis, 2 Dec 2015, ‘Is Australia becoming the world’s nuclear waste dump by stealth?’, Sydney Morning Herald, www.smh.com.au/comment/is-australia-becoming-the-worlds-nuclear-waste-dump-by-stealth-20151122-gl4v04.html